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GSA Schedule renewal


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I would advise that those are questions to ask the KO for your schedule contract.

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My company was small (SDB) when their GSA schedule was awarded and now, for option period 3, they are a large busines. Does size at time of award continue to rule ?, and therefore, no subplan is required for Option 3 renewal?

19.301-2 Rerepresentation by a Contractor That Represented Itself as a Small Business Concern.

(a) Definition. As used in this subsection—

Long-term contract means a contract of more than five years in duration, including options. However, the term does not include contracts that exceed five years in duration because the period of performance has been extended for a cumulative period not to exceed six months under the clause at 52.217-8, Option to Extend Services, or other appropriate authority.

(b ) A contractor that represented itself as a small business concern before contract award must rerepresent its size status for the North American Industry Classification System (NAICS) code in the contract upon the occurrence of any of the following:

(1) Within 30 days after execution of a novation agreement or within 30 days after modification of the contract to include the clause at 52.219-28, Post-Award Small Business Program Rerepresentation, if the novation agreement was executed prior to inclusion of this clause in the contract.

(2) Within 30 days after a merger or acquisition of the contractor that does not require novation or within 30 days after modification of the contract to include the clause at 52.219-28, Post-Award Small Business Program Rerepresentation, if the merger or acquisition occurred prior to inclusion of this clause in the contract.

(3) For long-term contracts—

(i) Within 60 to 120 days prior to the end of the fifth year of the contract; and

(ii) Within 60 to 120 days prior to the date specified in the contract for exercising any option thereafter.

( c) A contractor must rerepresent its size status in accordance with the size standard in effect at the time of its rerepresentation that corresponds to the NAICS code that was initially assigned to the contract.

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As part of the Option evaluation process, your GSA CO should require your company to re-represent its size status. As stated by Napolik, as this contract is longer than 5 years in duration (when considering options), a contractor must re-represent their size status 60-120 days prior to the date specified in the contract for exercising any option thereafter.

Therefore a simple answer to your question is No, your company's size at award does not stay valid for the 20-year possible term of the contract. If your company is now "other than small", it will have to have a sub-contracting plan.

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